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Parallel Proceedings

Maryland Criminal Tax Lawyer Explains Parallel Proceedings

The federal government is serious about combatting taxpayer fraud and misconduct.  Depending upon the circumstances of a case, a taxpayer may face both a civil audit and a criminal investigation at the same time.  When an IRS civil examination is conducted simultaneously with a criminal investigation, the proceedings are referred to as “parallel proceedings” or “parallel investigations.”

Parallel proceedings involve separate but often coordinated investigations that can be very dangerous for the taxpayer.  When the IRS collects information in connection with a civil audit, the information may be used in a criminal investigation without the taxpayer’s knowledge.  It is very important to understand that while the IRS is not permitted to intentionally deceive a taxpayer by conducting a criminal investigation under the pretext of a civil investigation, the IRS generally does not have an affirmative obligation to alert the taxpayer that a criminal investigation has been opened.  Moreover, parallel proceedings can also involve multiple agencies such as where the Internal Revenue Service is investigating a taxpayer and shares information with another federal agency such as the U.S. Securities and Exchange Commission.

Providing Skilled Counsel and Advocacy in Parallel Proceedings

Parallel proceedings present unique risks and challenges.  Thorn Law Group is a premier national and international tax law firm that represents individual taxpayers, businesses, trusts and other organizations in a complete range of tax law controversies.  Clients in Maryland, across the U.S. and around the globe trust our firm to deliver the skilled advice and advocacy needed to resolve their most challenging tax law matters.

Whether your situation involves a parallel IRS civil audit and criminal investigation or simultaneous investigations by different federal agencies, our firm is fully prepared to handle the matter.  We can advise you on the difficult decisions that arise when parallel proceedings occur, such as when it is advisable to cooperate with the civil audit and when it is best to assert your Fifth Amendment right against self-incrimination.  Our tax attorneys will work with you to develop a comprehensive defense strategy that minimizes your exposure to fines, penalties and other liabilities while preserving and protecting your legal rights. 

Contact the Experienced Tax Attorneys at Thorn Law Group

With the trend leaning toward increased coordination and information sharing among government agencies in parallel civil, criminal and administrative proceedings, taxpayers who have been targeted for an IRS audit or criminal investigation should discuss their case with experienced legal counsel.  A knowledgeable attorney can identify when parallel proceedings may be improper and take quick action to address the matter.  A skilled lawyer can also provide clients with the guidance they need to make well-informed and prudent decisions throughout the entire course of both investigations.

If you are concerned about parallel proceedings or have questions involving another tax-related matter, schedule a consultation with Thorn Law Group today.  The tax attorneys in our Maryland offices will confidentially review your situation to determine all courses of action that may be available to you.  Call us today at (240) 235-5096 or email ket@thornlawgroup.com.


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